Tougher v. Commissioner

OPINION

Raum, Judge:

Petitioners seek the benefit of section 119 of the 1954 Code2 in respect of supplies (primarily groceries) purchased by Mrs. Tougher at the FAA commissary for family use. It should be noted at the outset, first, that personal, living, and family expenses are generally not deductible from gross income, sec. 262, and, second, that section 119 deals with exclusions from gross incomes, not deductions therefrom. In our view, section 119 does not authorize petitioners to subtract from Mr. Tougher’s reportable wages the expenditures which Mrs. Tougher made at the commissary for…